Modern Slavery Statement

Introduction

Pivotal Group (which includes Pivotal Growth Limited and its wholly owned subsidiaries such as Pivotal Innovation Lab Limited and Pivotal Financial Limited firms, collectively referred to as “we”, “our”) are committed to preventing modern slavery and human trafficking in our operations and supply chains. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015.

Our Organisation and Supply Chains

We are a financial services group operating primarily in the UK, providing services across Mortgages, Specialist Lending, General Insurance, and Life & Protection through our network of Appointed Representatives, advisers and employees.

Our supply chains include technology and platform providers, marketing and lead-generation partners, call-handling services, training providers, recruitment agencies, and facilities management.

Policies

We maintain a comprehensive Modern Slavery Policy aligned with our Anti-Financial Crime framework and Consumer Duty obligations. Our policies prohibit forced labour, require right-to-work verification, ban worker-paid recruitment fees, and ensure fair employment practices throughout our operations and supply chains.

Risk Assessment

We conduct annual risk assessments and identify the following key risk areas:

• Outsourced and offshore service providers
• Recruitment and temporary labour chains
• Marketing and lead-generation supply chains
• Facilities and non-core services
• Technology hardware and physical goods procurement

Due Diligence and Controls

Our approach includes:

• Risk-based supplier onboarding with modern slavery questionnaires
• Contractual clauses requiring compliance and audit rights
• Annual supplier attestations
• Enhanced due diligence where customer interactions reveal potential exploitation indicators
• Integration with our financial crime reporting procedures

Training and Awareness

All staff and advisers complete mandatory modern slavery training at induction and annually, with role-specific scenarios for customer-facing teams.

Reporting Mechanisms

We provide confidential whistleblowing channels for staff and suppliers. Suspected cases are escalated to our Compliance Director and, where appropriate, reported to the National Crime Agency.

Governance

The Board approves this policy and receives quarterly management information. The Group Chief Operating Officer maintains overall responsibility, supported by Network Compliance.

Continuous Improvement

We are committed to strengthening our approach year-on-year through enhanced supplier oversight, expanded training, and improved risk assessment processes.

This statement was approved by the Board on 17th June 2026.

Last updated: 17th June 2026 | Review date: 17th June 2027